20250703APPLICATION.pdf

David A.Collier AT&T Services,Inc.
AT&T Lead Regulatory Relations P.O.Box 11010
1� :=i V Reno,W 89520
775-527-4252 Wurekess
�` a J D�1 [e-mail]
'a pug i - TCS-T-25-01
July 2,2025 i. _3 COW'!"."
Monica Barrios-Sanchez
Commission Secretary Idaho Public Utilities Commission
11331 W.Chinden Blvd.
Building 8, Suite 201-A
Boise,ID 83720-0074
RE: Numbering "Safety Valve" request for Teleport Communications America,LLC
("TCAL")
Dear Ms Barrios-Sanchez:
On behalf of Teleport Communications America,LLC("TCAL"), we respectfully
request that the Idaho Public Utilities Commission("Commission")review the decision of the
HDR INC. Pooling Administration("PA")denying TCAL's application for 1 thousand-blocks of
numbers due to the expansion of employees that will need B-VoIP phone numbers in the Coeur
d'Alene rate center.
This request is based on the Federal Communications Commission("FCC")rules per 47
C.F.R. 52.15(g)(4) and pursuant to the Thousands-Block Number(NXX-X)Pooling
Administration Guidelines and the Central Office Code (NXX)Assignment Guidelines published
by the Industry Numbering Committee("INC").
The customer is requesting 100 numbers for the Coeur d'Alene rate center. TCAL has
developed a communications plan that the customer will implement and assign the numbers as
soon as they are made available.A copy of the customer's Letter of Intent is attached as
Confidential Exhibit A. This document is considered CONFIDENTIAL and therefore has been
printed on yellow paper and sealed in an envelope attached to this letter.
On April 6, 2025, TCAL submitted the"Thousand Block Application Form Part IA"to
the PA for 100 numbers. TCAL received a denial error message indicating the request did not
"meet the MTE("months-to-exhaust") and Utilization requirements" and advised that TCAL
could request a state waiver from the Idaho Commission if not in agreement with the decision.
The Months to Exhaust(MTE) and the Utilization requirements were not met. Documentation of
this request/denial is enclosed. TCAL currently owns only 208-500-6, 208-763-6 and 208-889-6
with approximately 2018 available numbers.
TCAL respectfully requests that the Idaho Commission overturn the PA's decision
expeditiously in the interest of our customer, as we are unable to satisfy the numbering needs of
this customer without such exception. There is not currently one contiguous block of 100
January 1.2018
0 2018 AT&T Intellectual Property.AT&T,Globe logo,and are registered trademarks and service marks of AT&T Intellectual Property and/or AT&T
affiliated companies.All other marks are the property of their respective owners.

contiguous numbers that do not begin with 8, in the Coerdalene inventory pool and so a new
code will need to be opened.
Any correspondence with the PA in this matter may be brought to the attention of the PA
responsible for the geography in question:
Agnes Rom
NANPA-Pooling Administrator
925-420-0129
arom,nanpa.coir,
Please let me know if you have any questions regarding this filing.
Sincerely,
X�j alL
David Collier
AT&T—Lead Regulatory Relations
[phone]
�aae 2

ATTACIRVIENT A
[CONFIDENTIAL ATTACHMENT A
FILED UNDER SEPARATE COVER]

ATTACHMENT B

Tracking Number: 986-COE R DALE E-1 D-3083146
Thousands-Block (NPA-NXX-X) and Central Office
Code (NPA-NXX) Application - Part 1
Revised: October 28,2024
Type of Application: ® New ❑ Modification' ❑ Disconnect
1.0 Applicant Contact Information
Service Provider OCN Name: TELEPORT COMMUNICATIONS AMERICA, LLC - ID
Headquarters Address: 5001 Executive Pkwy 21/V
City: San Ramon State: CA ZIP: 94583
Contact Name: Rowena Brown
Contact Address: 5001 Executive Pkwy 2W
City: San Ramon State: CA ZIP: 94583
Phone: [phone] E-Mail: [e-mail]
1.1 North American Numbering Plan Administrator2
Contact Phone: [phone] E-Mail: [e-mail]
1.2 General Information
NPA: 986 NXX3: X4:
LATA: 960 Service Provider OCN5: 808G
OCN Category 6: CLEC Parent Company OCN: 7125
Number of Thousands-Blocks Requested: 1
Switching Identification(Switching Entity/POI)CO Code:
Switching Identification(Switching Entity/POI)Thousands-Blocks: CRALIDXXXIX
Rate Center9: COERDALENE
Homing Tandem Operating Companylo:
Tandem Homing CLLITM":
1.3 Dates
Date of Application: 04/06/2025
Requested Effective Date CO Code12,13:

❑ By selecting this checkbox,I acknowledge that I am requesting an effective date 52 calendar
days from the date the Administrator processes the request.
Request Expedited Treatment CO Code: ❑Yes ❑ No
Expedite documentation must be provided when is "Request Expedite" =Yes and your company is
not its own AOCN.14
Expedite Explanation:
Requested Effective Date Thousands-Block15: 05/07/2025
❑ By selecting this checkbox,I acknowledge that I am requesting an effective date 24 days from
the date the Administrator processes the request.
Request Expedited Treatment Thousands-Block: ❑ Yes ® No
1.4 Thousands-Block/CO Code Information
CO Code Assignment Preference:
CO Codes that are Undesirable,if any:
Code Applicant Responsibility
It is the Code Applicant's responsibility to arrange input of Part 2 information into BIRRDS. The 45-
calendar day nationwide minimum activation interval for BIRRDS will not begin until input into
BIRRDS has been completed.
Thousands-Block(s)Assignment Preference: 986-271-6,986-271-7
Thousands-Block(s)that are Undesirable,if any: NPA-8XX-XXXX,666
® By selecting this checkbox,I acknowledge that I am willing to accept a Thousands-Block where
the underlying CO Code may not yet be activated in the PSTN and loaded in the NPAC on the
Thousands-Block effective date.16
1.5 Type of Request (Initial or Growth)
Initial Thousands-Block and/or CO code for the rate center: ❑Yes
If yes, attach evidence of authorization and proof of capability to provide Service within 60 days.
Growth Thousands-Block and/or CO Code for the rate center: ®Yes
If yes,attach months to exhaust worksheet.
Pool Indicator17: ❑Yes ❑ No
Update BIRRDS/LERG18: ❑Yes 0 No

1.6 Modification
❑ OCN: Intra-Company19 ❑ Switching Id ❑ Tandem Homing CLLI
❑ OCN: Inter-Company20 ❑ Part 1B ❑ Effective Date
❑ Rate Center ❑ Add New ISP Thousands-Block Port
1.7 Disconnect
Is this Thousands-Block Contaminated: ❑Yes ❑ No
If yes, are there over 100 ported TNs: ❑Yes ❑ No
If yes, are you exiting the market: ❑Yes ❑ No
❑ I acknowledge I have completed all Intra SP ports in the NPAC and protected the Thousands-
Block from further assignment.
Comments:
1.8 Certification Statement
I hereby certify that the information on this application is true and accurate to the best of my knowledge,
and that this application has been prepared in accordance with the Thousands-Block and Central Office
Code Administration Guidelines (TBCOCAG)posted to the ATIS web site(http://www.atis.org)as of the
date of this application 21
Signature of Applicant: ;Zocuec:a f�zcscva: Date: 04/06/2025
Instructions for filling out each Section of the Part 1 form:
Section 1.0: Contact information requires that Service Providers (SP) supply under "Applicant" the
company name, company headquarters address, a contact within the company, an address where the
contact person may be reached, in addition to the phone and e-mail address.
Section 1.2: The SP shall supply the Numbering Plan Area (NPA); the Local Access Transport Area
(LATA), which is a three-digit number that can be found in the iconectivo, LLC LERGTM Routing
Guide 22.The Operating Company Number(OCN)assigned to the SP and the OCN of its parent company.
An OCN is a four-character alphanumeric NECA-assigned Company Code or a four-character
alphanumeric identifier assigned by the iconectiv Telecom Routing Administration (TRA). The Switch
Identification (Switching Entity/POI) and for Central Office (CO) Code requests the Tandem Homing
CLLITM23 shall also be entered. Explanations of these terms may be found in the footnotes. In addition,
when requesting Thousands-Blocks or CO Codes for LRN or Pool Replenishment in a Pooling Rate
Center the number of Thousands-Blocks requested shall be supplied.
Section 1.3: The date the Service Provider(SP)completes the application shall be entered in this section.
For Central Office(CO)Code requests the Effective Date of the requested CO Code shall be entered. For

Thousands-Block requests and CO Code requests for LRN or Pool Replenishment a Pooling Rate Center
the Effective Date of the requested Thousands-Block shall be entered.
Section 1.4: For Central Office (CO) Code request, the Service Provider (SP) may indicate their
preference for a particular CO Code, e.g., 321-6XX, or indicate any CO Code that may be undesirable,
e.g., 321-6XX. When requesting Thousands-Blocks or CO Codes for LRN or Pool Replenishment in a
Pooling Rate Center, SPs may indicate their preference for a particular Thousands-Block, e.g.,NPA- 321-
9XXX, or indicate any Thousands-Blocks that may be undesirable,e.g.,NPA-321-6XXX.
Section 1.5: Service Providers (SP) indicate the type of request. Initial requests are for first applications
for a Thousands-Block and/or Central Office (CO) Code in a Rate Center, Growth applications are for
additional Thousands-Blocks and/or CO Codes in a Rate Center in which the Applicant already has
Numbering Resources, and provide the required evidence as ordered by the FCC.
Section 1.6 Service Providers (SP)indicate when the request is for a modification and the type of change.
Rate Center and Tandem Homing CLLI changes only apply to Central Office (CO) Codes. Part 113
changes only apply to Thousands-Blocks.
Section 1.7: Service Providers (SP) indicate when the request is for a disconnect. When the request is to
disconnect a Thousands-Block, SPs shall also indicate the updated/current information in regards to
contaminated Telephone Numbers (TN) on the Thousands-Block they are returning to the Industry
Inventory Pool. Thousands-Blocks with over 10%contamination(101 TNs or more) shall not be returned
to the Industry Inventory Pool except when a SP is exiting the market or is exchanging a Thousands-
Block that was identified as being over 10%contaminated. If the Thousands-Block being returned is over
10% contaminated, the North American Numbering Plan Administrator (NANPA) shall seek a new
Thousands-Block Holder.
1 Identify type and reason for change(s)in Section 1.6.
2 The contact information for the North American Numbering Plan Administrator (NANPA) may be located at
hftps://www.nanpa.com.
3 The NXX field is required for any Thousands-Block or Central Office(CO)Code modification or disconnect.
4 The X field is required for any Thousands-Block modification or disconnect.
5 Operating Company Number (OCN) assignments must uniquely identify the applicant. Relative to Central Office
(CO) Code (NPA-NXX) assignments and Thousands-Block (NPA-NXX-X) assignments, NECA-assigned Company
Codes may be used as OCNs. Companies with no prior CO Code or Company Code assignments may contact
NECA (800-228-8597) to be assigned a Company Code(s). Since multiple OCNs and/or Company Codes may be
associated with a given company, companies with prior assignment should direct questions regarding appropriate
OCN usage to the Telecom Routing Administration(TRA)on 732-699-6700.
6 Each OCN is categorized to identify the type of company associated with a Company Code / OCN. Such
information for a particular OCN is available in the LERGTM Routing Guide(LERG 1 table).
7 This is an eleven-character descriptor of the Switching Entity/Point Of Interconnection (POI) provided by the owning
entity for the purpose of routing calls. This is the eleven-character iconectiv® Common Language Location
Identification (CLLITM) Code of the applicant's Switching Entity/POI. (iconectiv® and Common Language® are
registered trademarks and CLCITM, CLLITM, LERGTM Routing Guide and TPMTM Data Source are trademarks and the
Intellectual Property of iconectiv®, LLC.)
8 This is an eleven-character descriptor of the Switching Entity/Point Of Interconnection (POI) provided by the owning
entity for the purpose of routing calls. This is the eleven-character iconectiv® Common Language Location
Identification (CLLITM) Code of the applicant's Switching Entity/POI. (iconectiv® and Common Language® are
registered trademarks and CLCITM, CLLITM, LERGTM Routing Guide and TPMTM Data Source are trademarks and the
Intellectual Property of iconectiv', LLC.)

9 Rate Center name shall be a tariffed Rate Center associated with toll billing and in the LERGTM Routing Guide.
1° Applies to any Central Office (CO) Code Applicant connecting to the Public Switched Telephone Network via a
tandem owned by a different Service Provider(SP).
11 This is an eleven-character descriptor provided by the owning entity for the purpose of routing calls. This shall be
the CLLI Code of the Switching entity/Point of Interconnection(POI), and is the same on Part 2, Form 1, Page 2 of 2.
12 Central Office (CO) Code Applicants should request an effective date that is at least 59 calendar days from the
submission of this form. It should be noted that interconnection arrangements and facilities need to be in place prior
to Activation of a CO Code. Such arrangements are outside the scope of these guidelines.
13 Requests for Central Office (CO)Code assignment shall not be made more than six months prior to the requested
Effective Date.
14 When your company is its own AOCN please provide the following in the remarks field: I act as my own AOCN and
agree to reduce the input timeframe to [enter days]. When your company is not its own AOCN please provide the
AOCN's acknowledgement and agree to reduce the input timeframe to [enter days] and expedite letter from your
homing tandem operating company when requesting a new CO Code.
15 Please ensure that the Central Office (CO) Code (NPA-NXX) of the LRN to be associated with this Thousands-
Block(s)is/will be active in the PSTN prior to the effective date of the Thousands-Block(s).
16 In NAS, Thousands-Blocks from CO Codes not activated in the PSTN are identified as Available Pending (AP) on
reports.
17 The Applicant shall indicate "Yes" if the Central Office (CO) Code being requested shall be used for Thousands-
Block Number Pooling or indicate"No"if the CO Code being requested shall be used for a non-pooled CO Code or a
dedicated customer where the Thousands-Block will not be built in BIRRDS.
18 The Applicant shall indicate "Yes" if the Dedicated Customer Central Office (CO) Code being requested, or the
Thousands-Block being ISP Thousands-Block Ported, shall be identified as Thousands-Block Number Pooled in
BIRRDS/LERGTM and have all 10 Thousands-Block records built. The Applicant shall indicate "No" if the CO Code
being requested shall be used as a non-pooled CO Code for a Dedicated Customer or the Thousands-Blocks being
ISP Thousands-Block Ported shall not be identified as Thousands-Block Number Pooled in BIRRDS/LERGTM and
have all 10 Thousands-Blocks built.
19 Select if you are the current Thousands-Block or Central Office(CO) Code Holder
20 Select if you are not the current Thousands-Block or CO Code Holder
21 The Thousands-Block/Central Office (CO) Code applicant certifies veracity of this form by signing their name, and
providing their title and date.
22 iconectiv®, LLC and Common Language®are registered trademarks and CLCITM, CLLITM, LERGTM Routing Guide
and TPMTM Data Source are trademarks and the Intellectual Property of iconectiv®, LLC.
23 This is an eleven-character descriptor provided by the owning entity for the purpose of routing calls. This shall be
the CLLI Code of the Switching entity/Point of Interconnection(POI), and is the same on Part 2, Form 1, Page 2 of 2.

Tracking Number: 986-COER DALE NE-ID-3083146
Months to Exhaust Certification Worksheet - TN
Level' - Appendix 1
Revised: October 28,2024
(worksheet to be used for Requests for Additional Thousands-Blocks and CO Codes for Growth)
Date: 04/06/2025 Service Provider OCN: 808G
Service Provider OCN Name: TELEPORT Rate Center: COERDALENE
COMMUNICATIONS AMERICA, LLC- ID
List all CO Codes NPA(s)-NXXs and Thousands-Blocks NPA(s)-NXX-X(s)2: 208-500-6, 208-763-
6, 208-889-6
Name of Applicant: Rowena Brown
Phone: [phone]-null E-Mail: [e-mail]
A.Available Numbers 3: 2018
B.Assigned Numbers: 926
C.Total Numbering Resources 4: 3000
D. Quantity of numbers activated in the past 90 days(increments of 1,000 or 10,000) and excluded
from the Utilization calculations: 0
List excluded CO Code(s)or Thousands-Block(s):
E.Previous 6-month growth history6:
Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Month 12
12 5 0 42 112 0
F.Forecast-Next 12 months7:
Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Month 10 Month 11 Mouth 12
1000 10 10 10 10 10 10 10 10 10 10 10
G.Average Monthly Forecast(Sum of months#1-6(Part F above)divided by 6)8: 175.000
H. Months to Exhaust 9:
Numbers Available for Assignment to Customers (A) = 11.531
Average Monthly Forecast(G)
Block Requested Available Numbers Months to Exhaust
1 2018 11.531

I.Utilizationio:
Assigned Numbers (B) x 100
Total Numbering Resources(C)— Excluded Numbers (D)
Explanation:
1 A copy of this worksheet is required to be submitted to the North American Numbering Plan Administrator(NANPA)
when requesting additional Numbering Resources in a rate center. For auditing purposes, the applicant shall retain a
copy of this document.
z List all Numbering Resources allocated to the Service Provider OCN for the requested Rate Center, including newly
acquired Central Office (CO) Codes (NPA-NXX) and Thousands-Blocks (NPA-NXX-X). This information is available
from the Total Numbering Resources Report in NAS and shall automatically populate on this form in NAS. When an
exception exists, the Applicant shall adjust the auto-populated list and shall provide an explanation of the adjustment
in the Explanation field.
3 The total quantity of numbers available for assignment from the Numbering Resources allocated to the OCN for the
requested Rate Center, including newly acquired CO Codes (NPA-NXXs) and Thousands-Blocks (NPA-NXX-Xs).
When an exception exists, the Applicant shall adjust the auto-populated number as needed and provide an
explanation of the adjustment in the Explanation field (e.g., to increase the number of available resources due to
pending applications in the same rate center, or for documentation purposes for safety valve waivers).
4 The total quantity of Numbering Resources allocated to the Service Provider OCN for the requested Rate Center,
including newly acquired CO Codes(NPA-NXXs)and Thousands-Blocks(NPA-NXX-Xs).This information is available
from the Total Numbering Resources Report in NAS and shall automatically populate on this form in NAS. When an
exception exists, the Applicant shall adjust the auto-populated number as needed and provide an explanation of the
adjustment in the Explanation field (e.g.,to increase the total number of resources to include pending applications in
the same rate center,or for documentation purposes for safety valve waivers).
5 Quantity of numbers activated in the past 90 days indicates newly acquired Thousands-Blocks(NPA-NXX-X) and/or
Central Office (CO) Codes (NPA-NXX) received from the administrator and shall be reported in increments of 1,000
or 10,000 TNs(e.g.-.2 Thousands-Blocks received=2,000 and 1 CO Code received= 10,000).
6 Net change in Telephone Numbers (TN) no longer available for assignment in each previous month, starting with
the most distant month as Month 1, and Month 6 as the current month.
7 Forecast of Telephone Numbers (TN) needed in each following month, starting with the most recent month as
Month 1.
6 This field is automatically calculated and populated on this form in NAS.
9 This field is automatically calculated and populated on this form in NAS. To be assigned an additional Thousands-
Block(NPA-NXX-X) and/or Central Office(CO) Codes (NPA-NXX)for growth, "Months to Exhaust"shall be less than
or equal to 6 months. (47 CFR§52.15(g)(4) (iii)).
10 This field is automatically calculated and populated on this form in NAS. To be assigned an additional Thousands-
Block (NPA-NXX-X) and/or Central Office (CO) Codes (NPA-NXX) for growth, "Utilization" shall be 75% or more (47
CFR§52.15(h)). Newly acquired Numbering Resources may be excluded from the Utilization calculation (47 CFR§
52.15(g)(4)(ii)).

Tracking Number: 986-COER DALE NE-ID-3083146
Administrator's Response/Confirmation - Part 3
Revised: October 28,2024
Date of Application: 04/06/2025 Effective Date:
Date of Response: 04/06/2025
❑ Request Approved ❑ Request Suspended
❑ Request Withdrawn ® Request Denied
Administrator Comments:
The Months to Exhaust (MTE) and/or Utilization requirements were not met. This Part 3 denial
may be used to request a state waiver from the appropriate state commission.
If you are in disagreement with the disposition of this request,_please refer to the Thousands-
Block (NPA-NXX-X) & Central Office Code (NPA-NXX) Administration Guidelines for the
appeals process.
NPA,NPA-NXX,NPA-NXX-X: 986
Rate Center: COERDALENE State: ID
❑ Assigned ❑ Modified ❑ Disconnected
Thousands-Block Contaminated: ❑Yes ❑ No
If yes,the number of TNs contaminated(1-1000):
❑ Reserved Reservation Expiration Date:
Service Provider OCN Name: TELEPORT COMMUNICATIONS AMERICA, LLC - ID
Service Provider OCN: 808G OCN Category: CLEC
Parent Company OCN: 7125 NPAC SPID:
Switching Identification(Switching Entity/POI): CRALIDXXXIX
Tandem Homing CLLITM:
Applicant Contact Name: Rowena Brown
Phone: [phone] Email: [e-mail]
Administrator Contact Name: Agnes Rom
Phone: [phone] Email: [e-mail]